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Methane Emission Standards for Crude Oil and Natural Gas Facilities February 2018 Overview Background Regulation Requirements and Impacts Implementation 2 Background 3 Policy Drivers Climate Change Scoping Plans identify oil


  1. Methane Emission Standards for Crude Oil and Natural Gas Facilities February 2018

  2. Overview  Background  Regulation Requirements and Impacts  Implementation 2

  3. Background 3

  4. Policy Drivers  Climate Change Scoping Plans identify oil & gas sector as large source of Greenhouse Gas (GHG) emissions.  Combustion CO2 covered by Cap and Trade  Methane covered by this regulation  Short-Lived Climate Pollutant (SLCP) Strategy includes a target of 40-45 percent reduction in methane from oil & gas sector as a whole by 2025.  Recent, separate legislation addressing well stimulation and underground storage monitoring. 4

  5. California 2013 Methane Emission Sources Oil & Gas Extraction and Storage Landfills 4% 20% Pipelines 9% Industrial & Agriculture Miscellaneous 58% 5% Wastewater 4% 5

  6. California’s Oil & Gas Operations Dry Natural Gas  Third largest oil producer, (~1,700 wells) 15 th largest natural gas producer  Most natural gas is associated gas in California  Oil fields generally old, with enhanced recovery:  Thermal, well stimulation  Around 300 producers Crude Oil & impacted by regulation Associated Gas (~68,000 wells) 6

  7. ARB and District Responsibilities  ARB primarily responsible for mobile sources, fuels, and GHGs.  35 Local Air Districts responsible for stationary sources.  ARB’s responsibility can include stationary sources when Toxic Air Contaminants (TACs) or GHGs involved. 7

  8. Other Regulations  Districts regulating oil & gas for Volatile Organic Compounds (VOCs) for decades; exempt methane.  ARB’s regulation covers leaking equipment not already covered by air district rules.  Public Utilities Commission developed best practices to be consistent with ARB’s regulation.  ARB regulation covers new and existing sources, and is generally more stringent and broader than federal requirements. 8

  9. Regulation Requirements and Impacts 9

  10. Applicability  The regulation addresses fugitive and vented emissions of methane from both new and existing oil and gas facilities.  The covered facilities include: • Oil and Gas Production, Processing, and Storage • Gathering and Boosting Stations • Natural Gas Underground Storage • Compressor Stations 10

  11. Regulation Standards Separator and Tank Systems  Applies to systems at all regulated facilities.  Requires flash testing to determine annual methane emissions.  Requires systems with annual emissions above 10 metric tons (MT) methane to install vapor collection.  Exemptions for low throughput systems and small gauge tanks. 11

  12. Regulation Standards Circulation Tanks  Tanks used as part of a well stimulation treatment.  Operators institute a Best Practices Management Plan, followed by a control equipment technical assessment.  If technical assessment proves out, tanks controlled for emissions by January 1, 2020. 12

  13. Regulation Standards Leak Detection & Repair (LDAR)  Requires daily inspections and quarterly testing to check components for leaks.  Builds on current requirements by many districts to control VOCs.  Regulation will extend testing to methane at natural gas facilities.  Optical Gas Imaging for screening, but US EPA Method 21 for enforcement. 13

  14. Regulation Standards Underground Gas Storage  Monitoring program designed for the early detection of leaks: • Ambient air monitoring • Daily or continuous monitoring at injection/withdrawal wells. • Incorporates recent legislative requirements.  Operators submit monitoring plans to ARB for approval. 14

  15. Regulation Standards Natural Gas Compressors  Emission standards for reciprocating compressor rod packings and centrifugal compressor wet seals.  Requires either (1) replacement of high-emitting rod packing or wet seal, or (2) collection of leaking gas.  All compressors subject to LDAR. 15

  16. Regulation Standards Pneumatic Devices & Pumps  Continuous to no-bleed: • Air or electricity to operate; or, • Controlled with a vapor collection system Other Measuring and Reporting Requirements 16

  17. GHG Emission Reductions & Costs  Overall estimated annualized cost, with natural gas savings, of $27,300,000  Estimated continuing reductions of more than 1.4 million MT of CO2 equivalent per year, using a 20 year Global Warming Potential for methane.  Estimated overall cost-effectiveness of $19 per MT of CO2 equivalent reduced. 17

  18. Emission Reduction Co-Benefits  Over 3,600 tons per year (TPY) of VOC reductions statewide.  Over 100 TPY of reductions statewide of Toxic Air Contaminants, such as Benzene, Toluene, Ethyl- Benzene, and Xylenes.  Neutral statewide Oxides of Nitrogen (NOx) impact. 18

  19. Implementation 19

  20. Implementation Dates  January 1, 2018: • Flash testing • LDAR inspections • Natural gas storage monitoring plans • Registration and permitting  January 1, 2019: • Vapor collection on separator & tank systems • Pneumatic devices and compressor seal change-outs • Circulation tank technology assessment  January 1, 2020: • Circulation tank vapor collection, pending technology assessment 20

  21. Implementation  Regulation allows both ARB and the districts to implement; district implementation is preferred.  ARB and districts developed a model Memorandum of Agreement (MOA) to specify roles and responsibilities. • Coordinate enforcement, and support information and data sharing. • MOAs may be tailored for specific district needs. 21

  22. Implementation  About half of the MOAs have been signed; rest are in progress.  For most districts, CARB handling one-time facility and equipment reporting; districts handling “on the ground” enforcement .  Will review data being reported under program and monitor program implementation.  Will periodically update Board on status and propose adjustments as necessary. 22

  23. Questions?  Jim Nyarady, PE  jim.nyarady@arb.ca.gov  916-322-8273  https://www.arb.ca.gov/cc/oil-gas/oil-gas.htm 23

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